Scott M. Polakoff
Regional Director
Federal Deposit Insurance Corporation
500 West Monroe Street
Suite 3500
Chicago, LL 60661
Dear Scott,
We appreciate the FDIC issuing a new proposal to solicit additional
comments on the impacts of changing the definition of a small bank for
purposes of CRA to include those with total assets of up to $1 billion,
regardless of holding company affiliation.
Our Financial Institution strongly supports your proposal to increase
the size limit for community financial institutions eligible for the
small bank streamlined Community Reinvestment Act Examination from $250
million to S I billion. We also support establishing a community
development test which would permit more choice for my financial
institution to be evaluated based upon our community development
lending, qualified investments or community development services, as
opposed to all three. This proposal would also help my financial
institution to better compete with multibillion dollar financial
institution s for qualified investments.
The FDIC proposal would replicate the recently finalized OTS rule,
which raises the limit to $1 billion, effective October 1, 2004.
The proposed changes will not undermine the intended purpose of CRA
and would ease the paperwork and examination burden on my financial
institution.
Sincerely,
R.E. Coffman, Jr.
President & CEO
Oak Hill Financial
Jackson, OH
